Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments.
This week, we review the following developments as of Wednesday:...more
On February 20, 2025, House Majority Leader Steve Scalise (R-La.) issued a list of priority regulatory targets for nullification under the CRA “in the coming weeks.” Included on the list is the CFPB’s December 10, 2024 final...more
On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more
2/21/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Executive Orders ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Regulatory Reform ,
Stablecoins ,
Trump Administration
On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
2/7/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Government Efficiency ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration
On January 20, 2025, President Trump issued a Regulatory Freeze Pending Review (“Regulatory Freeze”) that applies to all executive departments and agencies. The Regulatory Freeze prohibits the proposal or issuance of any rule...more
1/27/2025
/ Artificial Intelligence ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Financial Services Industry ,
Hiring Freeze ,
Regulatory Freeze ,
Regulatory Reform ,
Rescission ,
Securities and Exchange Commission (SEC) ,
Trump Administration
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
8/6/2024
/ AML/CFT ,
Bank Deposits ,
Deposit Insurance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Request For Information ,
Risk Management ,
Third-Party Relationships
On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint...more
1/13/2023
/ Board of Governors ,
Cryptoassets ,
Decentralized Finance (DeFi) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
Fraud ,
Joint Statements ,
Misleading Impressions ,
OCC ,
Risk Management ,
Stablecoins ,
Unfair or Deceptive Trade Practices
Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more
12/15/2021
/ BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Reports ,
Cryptocurrency ,
Data Collection ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Libor ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Payment Systems ,
Ransomware ,
Redlining ,
Risk Assessment ,
Student Loans ,
TCPA ,
Technology ,
Truth in Lending Act (TILA) ,
U.S. Treasury ,
UDAAP ,
UDAP
Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more
3/2/2021
/ Arbitration ,
Banking Sector ,
BSA/AML ,
California Consumer Privacy Act (CCPA) ,
Comptroller ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Convertible Virtual Currencies (CVCs) ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Dodd-Frank ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
False Claims Act (FCA) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinCEN ,
Interest Rates ,
Interpretive Letters ,
Memorandum of Understanding ,
Military Lending Act ,
Minority-Owned Businesses ,
Mortgages ,
OCC ,
Payday Loans ,
PayPal ,
Preemption ,
Regulation D ,
SAR ,
SCOTUS ,
Small Business ,
State Attorneys General ,
TCPA ,
True Lender ,
Truth in Lending Act (TILA) ,
UK ,
Women-Owned Businesses
Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more
12/11/2020
/ Arbitration ,
Banking Sector ,
Bitcoin ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Data Breach ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
FRB ,
Main Street Lending Programs ,
Mobile Payments ,
OCC ,
Private Attorneys General Act (PAGA) ,
SBA ,
TCPA ,
Third-Party Service Provider
According to new guidance released on December 3, 2019, banks are not required to file suspicious activity reports (SARs) on customers solely because they are engaged in the legal growth or cultivation of hemp (“Guidance”)....more
The holidays came early for financial institutions when the Supreme Court agreed to hear a challenge to the constitutionality of the CFPB. We can expect fireworks in the New Year as two experienced Supreme Court practitioners...more
We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more
9/12/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FinCEN ,
GAO ,
HUD ,
Libor ,
Money Laundering ,
No-Action Letters ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
SHIELD Act ,
TCPA ,
Volcker Rule
On July 22, 2019, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”) issued a joint statement...more
On July 22, 2019, five federal agencies (the “Agencies”) published a final rule (the “Final Rule”), which conforms the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
The fireworks have started early this year. On May 2, a federal court in New York rejected the OCC’s motion to dismiss the lawsuit brought by the NY DFS challenging the OCC’s fintech charter. The decision has something for...more
6/18/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
TCPA ,
UDAP
On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money transmission. In connection...more
On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a guidance, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies (CVC) (“Guidance”), together with...more
On April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...more
On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a press release announcing a civil money penalty for violations of the Bank Secrecy Act’s (“BSA”) anti-money laundering (“AML”) compliance program...more
On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more
The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...more
EDITOR’S NOTE -
In the words of Willie Wonka: “Wait a minute — strike that, reverse it!” As loyal readers will recall, in our last issue, we tried to stay current in referring to the CFPB by what Mick Mulvaney declared...more
3/11/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
FDIC ,
Financial Services Industry ,
Payday Loans ,
TCPA ,
Truth in Lending Act (TILA) ,
Volcker Rule